Montana’s grace period on Medicaid expansion work rules ended September 30, and adults who cannot document 80 hours a month of approved activity can now lose coverage. The state began the requirement July 1, three months of warnings came first, and the clock for enforcement started in October.
Three months of warnings are over
The Montana Department of Public Health and Human Services, known as DPHHS, started the requirement July 1, 2026, ahead of the federal deadline of January 1, 2027. Montana is the second state to start early, after Nebraska began on May 1, according to Yellowstone Public Radio.
From July through September, DPHHS notified members who were not in compliance but did not cut their coverage, Missoula Current reported. The Montana Budget and Policy Center says DPHHS promised not to disenroll anyone or deny a new application or renewal over the rules in those three months, sending an “informational notice/warning” instead.
That protection ended with September. The policy center’s analysis of the DPHHS plan says that starting in October, enrollees who are out of compliance and not exempt become subject to the disenrollment procedure. Anyone who got a warning letter this summer is now past the point where it came without consequences.
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Federal law requires every state to have the rules running by January 1, 2027, the policy center notes, so Montana is six months ahead of that deadline. Federal law also requires four months of outreach before a start, and DPHHS said in the spring that it aimed to send member notices by March 31.
What counts toward 80 hours
The DPHHS Medicaid changes page says adults 19 to 64 must complete 80 hours a month of approved activities unless an exclusion applies. Paid or in-kind work counts, shown by income of at least $580 a month, or 80 hours of documented work if income cannot be verified.
Volunteer service with a not-for-profit counts. So do an approved state or federal workforce training or job readiness program, an internship or apprenticeship, and school at least half time. A mix of those activities can add up to the 80 hours.
Eligibility is checked at application, for the month before applying, and again at each redetermination, the yearly review of whether a person still qualifies. Starting January 1, 2027, redeterminations move to every six months, and DPHHS says some cases will be pulled forward to 2027 dates.
When DPHHS cannot verify compliance from data it already holds, members may need to submit its Appendix A and B forms with supporting documents. Members who do not meet the requirement receive a Notice of Adverse Action and can appeal through a fair hearing.
Who is exempt from Montana’s work rule
DPHHS lists several groups the requirement does not apply to. They include American Indians and Alaska Natives, former foster youth under 26, medically frail people, and parents, guardians or caregivers of a dependent child under 14 or a disabled person. People in drug or alcohol treatment, pregnant and postpartum women, and veterans with a 100% disability rating are also on the list.
People already meeting SNAP or TANF work requirements are covered as well. Separate short-term exceptions count only for the months they apply: people with Medicare Part A or B, people who were incarcerated in the last three months, inpatients, residents of a county under an emergency disaster declaration, and people who must travel for serious medical care.
DPHHS says it will not use the high-unemployment county exception at this time, even though the federal rules allow it. A person in a county with weak job numbers gets no automatic pass from that route in Montana.
How many Montanans could be affected
The Missoula Current reported that 73,895 adults were on Medicaid expansion as of March, out of 207,902 people enrolled in Medicaid or Healthy Montana Kids. The Montana Budget and Policy Center put the group subject to the requirements at nearly 77,000.
DPHHS Director Charlie Brereton said the department is “fully prepared for this transition,” with staff trained and exemption processes and systems ready. YPR reports the department is hiring 59 new employees to handle the workload.
Heather O’Loughlin, executive director of the Montana Budget and Policy Center, warned that the people who lose coverage are often those who qualify but miss paperwork or cannot reach the department. “The biggest issue here is additional layers of paperwork,” she said.
O’Loughlin also said the state has not reported publicly how many people have received notification, or released updated numbers on compliance and exemptions. The policy center’s analysis adds that the timing of the 30-day response window and the 10-day advance notice before a fair hearing was unclear.
Members can report hours or update information at apply.mt.gov, by calling the Public Assistance Helpline at 1-888-706-1535, by mail to the Human and Community Services Division, PO Box 202925, Helena, MT 59602-2925, or in person at a local Office of Public Assistance.
Did a Montana Medicaid work-rule warning arrive this summer?
A member who qualifies for an exemption can still lose coverage if the paperwork never reaches DPHHS. A Notice of Adverse Action follows when the department cannot verify the hours, and the six-month renewals that start January 1 add another chance to miss a form.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, with a renewal document checklist and a renewal and reporting calendar. It includes 51 state packs, so Montana’s rules sit alongside the 90-day window after coverage is dropped.
Get the Medicaid renewal organizer with the document checklist and reporting calendar →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
